Since 12 August 2026, every company that places packaged goods on the EU market must be able to prove that each packaging component meets the Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40). For suppliers outside the EU, this changes what your European customers will ask for.
A one-page letter saying "our packaging complies with the PPWR" no longer does the job. Your customer needs data on every packaging element — the cardboard box, the stretch film, the tape, the pallet — and ideally a technical or chemical data sheet for each one. This article explains why, and what a complete supplier package looks like.
Where non-EU suppliers sit in the PPWR
The PPWR rarely obliges a non-EU supplier directly, but almost every obligation of your EU customer depends on your data. The regulation assigns duties by role:
Role | Who it is | Core PPWR duty |
Manufacturer | Whoever places packaging or a packaged product on the market under its own name or brand — not necessarily who physically made it | Conformity assessment, technical documentation (Annex VII), EU declaration of conformity (Annex VIII), labelling; keep records 5 years (single-use) or 10 years (reusable) |
Importer | The EU company that first places packaging or packaged goods from a third country on the EU market | Verify before placing on the market that the manufacturer did the conformity assessment and drew up the technical documentation; keep a copy of the declaration; supply documents to authorities within 10 days of a request (Art. 18) |
Supplier of packaging or packaging materials | You, if you deliver packaging, packaging materials or packaged products upstream | Provide the manufacturer with all information and documentation needed to demonstrate conformity, including the Annex VII technical documentation and the data required under Articles 5 to 11, in a language the manufacturer understands (Art. 16) |
In practice, non-EU suppliers end up in one of two situations:
- You ship packaged goods to an EU importer. If the goods are sold under your customer's brand, your customer is the manufacturer and signs the declaration. If they carry your brand, the importer must verify your documentation. Either way, the evidence comes from you.
- You supply packaging materials to an EU manufacturer. Article 16 applies directly: your customer cannot sign its declaration without your information.
EU authorities can rarely enforce against a supplier in Viet Nam, Brazil or Türkiye. They enforce against your customer — who will pass the requirement back to you through purchase terms, supplier questionnaires and, ultimately, supplier selection.
Why a blanket declaration is not enough
A declaration is a statement; the PPWR asks for proof. The EU declaration of conformity is only the front page of a file. Behind it sits the technical documentation of Annex VII: a description of the packaging, its material composition, evidence on restricted substances, test results and the standards applied. If an authority requests that file and your customer cannot produce it, conformity counts as not proven.
The typical supplier letter fails that test for five reasons:
- It names no packaging. "All our packaging complies" does not say which box, which film or which product it covers. The PPWR works per packaging type.
- It contains no materials. Your customer cannot see whether the box is corrugated board, the film is LDPE or LLDPE, or whether there is a coating, ink or adhesive layer.
- It contains no evidence. Since 12 August 2026, the sum of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg in any packaging or packaging component (Art. 5(4)). For food-contact packaging, PFAS limits of 25 ppb (any single PFAS), 250 ppb (sum of targeted PFAS) and 50 ppm (total PFAS) apply (Art. 5(5)). A sentence is not a test result.
- Nobody can check it. Without weights, materials and data sheets, your customer has nothing to test for plausibility — and its market surveillance authority has even less.
- It is useless for what comes next. Labelling requirements follow in 2028; recyclability grades and recycled-content targets for plastics follow from 2030. All of them need material data per component, not a general statement.
The practical consequence: your customer must either chase you for the details later or replace you with a supplier who provides them up front.
Think in packaging levels and components
The right unit of documentation is the individual packaging element, grouped by packaging level. Take a flat-packed furniture item shipped from Asia to a German importer. What looks like "the packaging" is in fact six or more components from four or five different material suppliers:
Level | Element | Material | Weight per unit (illustrative) | Evidence to attach |
Primary (sales) packaging | Shipping carton | Corrugated cardboard, brown, double wall | 1,250 g | Technical data sheet of the board; heavy-metal test report |
Primary (sales) packaging | Print on carton | Water-based flexo ink | < 5 g | Ink manufacturer's data sheet and safety data sheet |
Primary (sales) packaging | Corner protectors | Moulded paper pulp | 80 g | Technical data sheet; heavy-metal test report |
Primary (sales) packaging | Sealing tape | PP film with acrylic adhesive | 15 g | Technical data sheet of the tape |
Secondary (grouped) packaging | Stretch film around 10 cartons | LLDPE, 23 µm, 30% recycled content | 140 g | Technical data sheet; composition; recycled-content evidence; heavy-metal test report |
Transport packaging | Pallet | Solid wood, heat-treated (ISPM 15) | 22 kg | Material description; ISPM 15 marking |
Each row answers a different question for your customer. The carton determines the paper waste stream, the stretch film the plastics stream, and the ink and tape decide whether the carton is easy to recycle. A single declaration covering "the packaging" answers none of them.
What to provide for each component
For every packaging element, your EU customer needs the same core set of data:
Data point | Example (stretch film) | Why it matters |
Packaging level and element | Secondary packaging, stretch film | Maps the element to the customer's declaration |
Product(s) it is used for | Item codes 4711, 4712 | Links the data to the packaging type being declared |
Material and grade | LLDPE, cast film, 23 µm | Waste stream, recyclability, future design-for-recycling grade |
Composition by weight | 100% PE, no PVC, no PVDC | Mono-material vs multi-material |
Weight per unit | 140 g per pallet unit | Minimisation and EPR reporting |
Additives, coatings, inks, adhesives | Tackifier (PIB), uncoloured | Recyclability and substance compliance |
Heavy metals (Pb + Cd + Hg + Cr VI) | < 100 mg/kg, test report no. and date | Art. 5(4), applies now |
PFAS (food-contact packaging only) | Below 25 ppb / 250 ppb / 50 ppm | Art. 5(5), applies now |
Recycled content | 30% post-consumer, with certificate | Recycled-content targets for plastics from 2030 |
Packaging material supplier | Name and site of the film producer | Traceability, plausibility checks |
Date and version | v2, 15 September 2026 | Shows the data is current |
The data sheet: one per component
The strongest evidence is a technical data sheet for each component, issued by the company that produced the material. A good data sheet states the material specification (grammage or thickness, grade), the composition, relevant test results and the standards applied. Ideally it is accompanied by a test report on heavy metals and, for food contact, on PFAS.
Two points avoid frequent misunderstandings:
- Technical data sheet vs safety data sheet. Cardboard, film and pallets are articles; they come with a technical data sheet, not a REACH safety data sheet. Inks, adhesives and coatings are mixtures; for these, ask for the safety data sheet as well.
- Pass documents through, do not retype them. Request the data sheets from your own packaging suppliers — the box maker, the film producer, the ink supplier — and forward them. An original document from the material producer carries more weight than a summary in your own words.
Checklist for non-EU suppliers
- ☐ List every packaging element for each product you ship to the EU, grouped into primary, secondary and transport packaging
- ☐ Record material, grade, weight and dimensions for each element
- ☐ Request a technical data sheet from each packaging material supplier (carton, film, tape, corner protectors, pallet)
- ☐ Request safety data sheets for inks, adhesives and coatings
- ☐ Obtain heavy-metal test reports (sum of Pb, Cd, Hg and Cr VI below 100 mg/kg) for each material
- ☐ For food-contact packaging, obtain PFAS test results against the three Article 5(5) limits
- ☐ Document recycled content with a certificate or supplier confirmation
- ☐ Link each packaging set to the item numbers your customers use
- ☐ Date and version every dataset, and tell customers when packaging changes
Collect once, share with every buyer
If you sell to five EU importers, expect five different questionnaires. The underlying data is the same each time. Suppliers who build one structured packaging dataset per packaging type — components, materials, weights, data sheets — can answer every request in minutes instead of weeks, and keep it current in one place.
This is the model behind supplier data platforms such assupplycanvas: suppliers enter packaging data and documents once and share them with all their buyers, who use them to build their own declarations of conformity.
Conclusion
Under the PPWR, your EU customer signs or verifies the declaration of conformity — but the evidence behind it comes from you. A generic compliance letter shifts the work back to your customer and puts the business relationship at risk. Component-level data, backed by a data sheet for each element, turns PPWR from a hurdle into a reason to choose you as a supplier.